In this Keynote address, Grant gave an overview of the timeline and issues on Pillar 1 and Pillar 2. This included discussion of the main themes, difficult issues and the likely scenarios going forward. He also discussed the prospect of additional digital services taxes and other potential international tax developments.
Building off its success in the Australian market, Masks has started to see demand for its products in overseas jurisdictions. Masks is now selling its products to customers in several countries in the Asia-Pacific region via a series of distributors operating as agents for Masks in the overseas jurisdictions. One of Jane and Judy's business contacts operates a bonded warehouse in Singapore and has agreed to let Masks use this facility for the purposes of warehousing products until sales are made. Some of the issues covered:
- commercial due diligence on foreign market (e.g. local registrations; local bank accounts)
- understand agency arrangement and remuneration of agent (treaty overlay)
- source under Australian domestic tax law
- treaty permanent establishment issues around warehousing/storage
- transfer pricing - location of functions, assets and risks
- indirect tax issues and customs duties (local jurisdiction).